GR 131377; (February, 2003) (Digest)
G.R. No. 131377 ; February 11, 2003
PEOPLE OF THE PHILIPPINES, petitioner, vs. HON. NAZAR U. CHAVES, Judge, RTC-Cagayan de Oro City, Br. 18 and MIGUEL P. PADERANGA, respondents.
FACTS
In Criminal Case No. 86-39 for Multiple Murder, the prosecution sought to present accused Felizardo Roxas as a witness against his co-accused, including private respondent Atty. Miguel Paderanga. The trial court sustained Paderanga’s objection, ruling that presenting Roxas would violate his right against self-incrimination unless he was first formally discharged as a state witness under Rule 119, Section 9 of the Rules of Court. The prosecution then moved to discharge Roxas as a state witness.
During the hearing on the motion for discharge, the trial court initially allowed the prosecution to present Roxas’s oral testimony to prove he met the legal qualifications for discharge. However, upon Paderanga’s motion for reconsideration, the court reversed itself. It held that the “evidence” required by the rules to support a discharge must be evidence other than the proposed witness’s own testimony, limiting the prosecution to presenting only the sworn statement of the accused. The Court of Appeals upheld this ruling, prompting the People’s petition for review.
ISSUE
Whether the trial court correctly prohibited the prosecution from presenting the oral testimony of an accused at a hearing for his discharge as a state witness, limiting proof to his sworn statement alone.
RULING
The Supreme Court reversed the Court of Appeals. It held that the trial court’s interpretation of Rule 119, Section 9 was erroneous. The provision requires the prosecution to present “evidence and the sworn statement of each proposed state witness.” The Court clarified that this disjunctive phrasing means the court must consider both types of proof: (1) other evidence, and (2) the sworn statement itself. The sworn statement is a distinct, required component, not a substitute for other evidence.
The legal logic is that the hearing aims to determine if the accused qualifies for discharge—e.g., that his testimony is absolutely necessary and he is not the most guilty. This determination necessitates a searching inquiry, which can include examining the accused in open court to assess his credibility, voluntariness, and the substance of his proposed testimony. Restricting proof to the sworn statement alone would deprive the court of a critical tool to verify the statement’s veracity and the accused’s demeanor. The rule’s purpose is to ensure a judicious exercise of discretion, which is best served by allowing oral testimony at the discharge hearing. The trial court was directed to allow the presentation of the accused’s testimony for this purpose.